[BC] Minimum staffing

[Broadcast List USER]

Actually Mike, I think we are writing the same thing, only I didn't  
write a 38 page memo covering every possibility.

You need to have the doors open during business hours, and you need  
to have a full time management employee.

When the manager isn't available, you STILL need to have to doors  
open, and provide access to the Public File.

 From what I have read, you cannot hang up a sign that reads, "Back  
at 4:30 PM."  THAT is where the part-time/shared employee fits into  
the program.

I have trusted the attorneys, but I showed up at a station that I was  
working for, and found it locked, with a phone number to call.  I  
did, and I was met very promptly.  I then called the in-house  
attorney and he went NUTZ.  He stated that is was but for the Grace  
of God I was not from the FCC or someone with an agenda who would  
have gone to the FCC.

I don't think there is ANYTHING in the rules about 1.5 employees, but  
having the main studio open IS in the rules.  The rest is defined by  
court cases and fines.  I really don't think leaving to make a bank  
deposit is something that is going to be looked upon as reasonable if  
the FCC Inspector is left cooling his heals at the front door for 90  
minutes!  What about that member of the public who is waiting to see  
the Public File?

Regarding the FCC knows people and managers must perform their  
duties...  I have spoken with some very good friends who have worked  
there for a long time, and some for not so long a time, and most of  
them are pretty upset that stations are not run like radio stations  
used to be run.  They not only think that management must be there  
all the time, but that the station should have someone at the studio  
24 hours a day, every day.  I don't disagree.  The station is allowed  
to use a public resource, the spectrum, essentially free of charge,  
and (at least in the past) was able to use that to make a TON of  
money by using it.  I believe the station needs to give back, and  
part of that is the ability to respond to things going on in the area  
and make announcements to the public at large -- after all, isn't  
that what BROADCASTING is about.

Still, I really don't see a problem with every station in an area co- 
locating in one building, and letting one person be on duty, as long  
as that person can take over every station and notify the public as  
needed.  Of course, the do need a reasonable back-up for that  
critical single point of failure.

--chip

On Mar 2, 2009, at 3:36 PM, broadcast-request at radiolists.net wrote:

> Message: 12
> From: Mike McCarthy <Towers at mre.com>
>
> All due respect Chip, you are completely incorrect on a very  
> important point.
>
> The licensee MUST have a at least ONE full-time management level
> employee located at the main studio location.  Additionally, a 2nd
> employee of undefined hours is also needed.  That 2nd person can be
> shared or be part time.
>
> The FCC knows people and managers must perform their duties inside
> and outside the office and that employees are afforded meal breaks.
>
> Let's not forget where ever you have EAS equipment and a means to
> control the transmitter, that is technically a control point as well.
>
> We have three such configurations and have passed muster on all three.
>
> MM